ML13312A765
| ML13312A765 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/24/1994 |
| From: | Marsh W Southern California Edison Co |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9403080375 | |
| Download: ML13312A765 (8) | |
Text
Southern California Edison Company 23 PARKER STREET IRVINE, CALIFORNIA 92718 WALTER C. MARSH February 24, 1994 TELEPHONE MANAGER OF NUCLEAR REGULATORY AFFAIRS (714) 454-4403 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Docket Nos. 50-206, 50-361 and 50-362 Semiannual 10 CFR 26 Fitness for Duty Program Data San Onofre Nuclear Generating Station, Units 1, 2 and 3 Pursuant to 10 CFR 26.71(d), this submittal provides the required semiannual Fitness for Duty program performance data for the period July 1, 1993 to December 31, 1993 (Attachment 1). is a summary of information and management actions for the reporting period. Attachment 3 graphically illustrates key elements included in Attachment 1. Attachment 4 provides the annual program data, including the annual random testing rate.
If you require any additional information, please so advise.
Sincerely, Attachments:
10CFR26 Performance Data cc:
K. E. Perkins, Jr., Acting Regional Administrator, NRC Region V M. K. Webb, NRC Project Manager, San Onofre Unit 1 M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3 J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3 R. F. Dudley, Section Chief, Non-Power, Decommissioning, and Environmental Project, Directorate of Reactor Projects 3, 4 and 5 9403060375 940224 PDR ADOCK 05000206 R
Fitness for Duty Program ATTACHMENT 1 Performance Data Page 1 of 2 Personnel Subject to 10CFR I6 Southern California Edison July 1 -
December 31, 1993 Company 6 Months Ending San Onofre Nuclear Generating Station Location T.M. Calloway, Mgr., Access Authorization (714) 368-9554 Contact Name Phone Number Cutoffs: Screen/Confirmation (ng/ml)
Marijuana 50/10 Barbiturates 300/200 Cocaine 300/150 Benzodiazepine 300/300 Opiates 300/300 Methadone 300/200 Amphetamines 1000/500 Propoxyphene 300/200 Methamphetamine 1000/500 Phencyclindine 25/25 Amphetamine
/200 Alcohol (%BAC)
.04 Testing Results SCE Employees Contractor Personnel Total Average Number with Unescorted Access 2479 1727 4206 Test Types
- Tests
- Failures
- Tests
- Failures Pre-Badging 204 1
974 19 For Cause 1
1 2
0 Post Accident 0
0 0
0 Random 1118 3
1030 12 Follow-Up 68 1
77 1
Other 57 0
22 0
Total 1448 6
2105 32 Number of Employees Referred To Mandatory Treatment 3
Number of Personnel With Access Restored Employees 4
Contract 10 Total Number of Random Tests 2148 Random Testing Rate 51.1%
ATTACHMENT 1 Table 1 RANDOM TESTING PROGRAM RESULTS Page 2 of 2 See Attachment 3, Figure 1 Individuals Tested 1989 1990 1 9 9 1 1992 1993
- Failed N/A 1
118 12 11 14 4
4 10 15
- Tested N/A 302*
2422 1842 1771 2604 1986 1890 1947 2148
% Failed N/A 1.3%
1.7%
1.6%
.6% 1.5%
1.2%
1.2%
.5%
1.7%
- Represents only two months of testing.
Table 2 BREAKDOWN OF CONFIRMED POSITIVE TESTS FOR SPECIFIC SUBSTANCES 7/01/93 -
12/31/93 Includes multiple submittals/multiple substances detected.
Marijuana Cocaine Opiate Amphet Phencyc Alcohol Barb Benzo Methadone Prop Refusals 100/1 5a 50/1 Ob Licensee Employees 2
2 0
12 5
0 1
7 6
0 1
0 Contract Workers 19 28 4
15 14 1
0 3
10 0
2 0
Total Totals 21 30 4
27 19 1
1 10 16 0
3 0
111
- on-site presumptive a - N R Levels b - SCL Levels N/A 23 5
- certified Lab GCIMS I
c - 30 samples were reported positive by the HHS lab of those; 2 were not pre-screened and 5 samples pre-screened confirmed N/A 25c 4d negative and reported positive at or near cut-off levels.
Confirmation Ratio N/A 82%
80% J d - One sample pre-screened on-site at cut-off level but was not reported by the off-site lab.
e - If marijuana had been tested at 50/15, results for this reporting period would have been; on-site presumptive 23,
total confirmed 27 (4 pre-screened negative but reported positive (see Attachment 2, item 9), for a Confirmation Ration of 82%.
Table 3 BREAKDOWN OF CONFIRMED POSITIVE TESTS CAUSING FAILURES 7/01/93 -
12/31/93 All Test Types See Attachment 3, Figure 2 for Breakdown of Failures by Test Type.
THC COC METH ETOH OPI BARB PCP Licensee Employees 1
0 2
3 0
0 0
Contract Workers 17 3
8 1
1 1
1 Total Total 18 3
10 4
1 1
1 38
ATTACHMENT 2 Page 1 of 3 (July 1, 1993 -
December 31, 1993)
- 1.
Management actions were inappropriately enacted by a licensee's supervisor against an SCE temporary employee following a drug test specimen submittal. The employee was terminated prior to specimen onsite prescreening analysis and subsequent DHHS lab confirmation.
Because of the circumstances associated with the individual's random test, supervision presumed the employee would test positive. The employee was initially reluctant to take the test and also conveyed fear of failing the test because of being at a party a few days earlier but, still denied use.
Once this action was brought to the attention of the Fitness for Duty Program Manager (and discussed with the employee's Manager) the individual was immediately reinstated to his previous employment and compensation status although administrative actions were taken. His-Protected Area access was suspended supported by an onsite prescreen presumptive positive test result for THC. The employee was fully compensated until all laboratory testing was complete and the MRO test failure declaration was made. Appropriate management actions were then invoked in accordance with the Licensee's program provisions.
The supervision involved in this incident was reminded of the rule restrictions governing Management Actions and Sanctions.
Licensee procedures and training are clear on this matter. This incident was believed to be an isolated individual performance matter, not programmatic in nature, and therefore did not warrant any program refinement.
No other Management or Administrative actions were initiated on onsite prescreen presumptive positives during this reporting period.
- 2.
A total of fifteen (15) individuals (three [3] employees and twelve [12] contract workers) had unescorted protected area access withdrawn for a minimum of 14 days following a random substance test failure. Twenty (20) individuals (one [1]
employee and nineteen (19] contract workers) were denied unescorted protected area access following a pre-badging substance test failure.
- 3.
As a result of a test failure, Three (3) employees were denied Site Access and had employment terminated.
- 4.
There were no transfers of licensee employees to non-nuclear positions (away from the San Onofre site) during this time frame as a result of failed substance tests.
- 5.
Three (3) employees were required to enroll in a treatment program during this period.
ATTACHMENT 2 Page 2 of 3
- 6.
Four (4) employees and ten (10) contract workers were granted (reinstated) unescorted access with a single test failure on record.
- 7.
The MRO reviewed a total of thirty-five (35) appeal results for four (4) employees and thirty-one (31) contract workers. The original test results were confirmed. These individuals were provided with detailed instructions regarding their rights to appeal management actions which resulted in access denial.
Twelve (12) workers pursued appeals through the management review process, the management actions were upheld.
- 8.
There were no identified deficiencies in the Fitness For Duty program.
- 9.
As depicted in Table 2, there were 111 samples collected that were confirmed by the lab as positive. As shown in Table 3, only 38 individuals were associated with MRO failed test declarations.
Due to the SCE recollection procedure, several individuals submitted multiple positive samples resulting in a single declared individual failure. Positive tests for prescription medications resulted in two (2) MRO declared non-contact failures, all others were declared responsible use by the MRO and did not result in a declared individual failure.
One sample pre-screened presumptive positive for cocaine while the HHS lab analysis of the sample was negative. Investigation to resolve the discrepancy between onsite and off-site lab results indicated the sample was positive at a concentration just below the cutoff resulting in a negative test.
This is within the range of predictable results.
In reconciling THC results, it was noted that five samples pre screened negative for THC while the HHS lab analysis was positive. Although a negative prescreen result for THC was obtained, all samples were sent for off-site analysis.
One sample, presumptive positive for prescription drugs, tested positive at the off-site lab for THC just above the cutoff level.
Four additional samples were submitted as multiple collections warranting off-site analysis in accordance with site program procedure. These samples were reported positive by the HHS lab.
In investigating the THC discrepancies, both HHS labs and on-site pre-screening utilized different EIA reagents for the detection of marijuana metabolites. Due to slight differences in sensitivity of the reagents used, in concert with borderline positive samples, the results were technically acceptable. On site pre-screen results and test protocol were verified by the reagent manufacturer and found to be accurate and consistent with the testing protocol. Appeal samples sent to a second HHS (appeal) lab confirmed the positive results.
ATTACHMENT 2 Page 3 of 3
- 10.
One (1) event was reported to the Commission (drug find) pursuant to 10 CFR 26 during this reporting period. The text of that report is duplicated below:
A.
A notification was made to the NRC Operations Center (Mr.
MacKinnon answering, Operations Center Log # 26272) on October 28, 1993, at (0635 ) PDT as follows:
"This notification is for San Onofre Units 2 and 3 and is being made pursuant to 10 CFR 26.73(a)(1).
This is a non-emergency twenty-four hour notification.
"A suspect material was discovered in the Protected Area at 1030 hrs. on October 27, 1993.
It was located in a generally non-accessible and remote area in the Unit 3 Containment.
The material was discovered by contract personnel while they were performing a polar.crane modification, which is the first such modification since initial construction.
"Confirmation of the suspect material is pending verification by an off-side laboratory (the remains of one suspected marijuana cigarette).
"There have been no individuals identified as being responsible for the material.
It is suspected that the controlled substance has been located in the generally non-accessible and remote area since initial Unit 3 construction (1978-1981 time-frame).
"Unit 2 was operating at approximately 100% power and Unit 3 was shutdown and de-fueled when the substance was discovered.
"In accordance with the provisions of 10 CFR 26.71(d),
information pertaining to this finding will be included in a summary submittal which will be submitted within 60 days of the end of the current 6-month reporting period, which concludes December 1993."
The SONGS Resident Inspector's Office was notified of this event at 0950 hours0.011 days <br />0.264 hours <br />0.00157 weeks <br />3.61475e-4 months <br />, October 28 1993.
ATTACHMENT 3 Page 1 of 1 Random Failure Rate 1989 - 12/31/93 0.8%
0.7%
0.7%
0.7%
.8%
0.8%
0.8%
.5%
0.5 0.5%
0.4%
- 0.
0.3%
- 0.
0.2%
0.1%
0%,
2 1
2 1
2 1
2 1
2 1989 l 1990 1
1991 l
1992 1993 1989 represented only two months of testing.
Figure 1 Failures by Test Type Pre-Badging 20 (53)%
For Cause 1 (3)%
Follow-Up 2 (5)%
Random 15 (39)%
7/1/93 -12/31/93 Figure 2
e'Fitness for Duty Progra' ATTACHMENT 4 Performance Data Page 1 of 1 Personnel Subject to 10CFR26 Southern California Edison January 1 -
December 31, 1993 Company 12 Months Ending San Onofre Nuclear Generating Station Location T.M. Calloway, Mqr., Access Authorization (714) 368-9554 Contact Name Phone Number The following data is a compilation of the two semi-annual data submittals for 1993.
It is provided to demonstrate fulfillment of the annual mandated testing rate.
Other references and narratives associated with the two semi-annual data submittals have not been replicated. For such, refer back to the individual submittals.
Testing Results SCE Employees Contractor Personnel Total Average Number with Unescorted Access 2462 1505 3967 Test Types
- Tests
- Failures
- Tests
- Failures Pre-Badging 463 2
2473 37 For Cause 3
1 3
1 Post Accident 0
0 0
0 Random 2238 9
1857 16 Follow-Up 139 2
121 1
Other 122 1
39 1
Total 2965 15 4493 56 Number of Employees Referred To Mandatory Treatment 8
Number of Personnel With Access Restored Employees 5
Contract 19 Total Number of Random Tests 4095 Random Testing Rate 103.2%